Submission on Application A549 Food derived from high-lysine corn LY038: to permit the use in food of corn genetically modified to produce high amount of lysine.

PSRG urges Food Standards Australia New Zealand to reject the above application. Corn products processed in Australia are likely to be supplied to markets in New Zealand and New Zealanders have the right to expect regulatory authorities to adopt a cautious approach to food safety and health considerations. On the grounds of human health and safety, PSRG believes that acceptance of this application is not warranted.

Considerations(1) Research consistent with the WHO published protocols has not been carried out on the effect of novel proteins on humans, chickens or pigs, the intended recipients of this corn feed. The novel proteins are likely to arise both as a result of the DNA insertion event and also as a result of a higher amount of the amino acid lysine within the cell. To assume that the increase in lysine and the DNA insertion process will not result in considerable changes to the levels of primary or secondary metabolites in the cell shows little regard for food safety. Food allergies to any new proteins are a very important food safety issue and should be tested for as such on an on-going basis.(2) The "inadvertent commingling" of conventional corn and LY038 would result in LY038 entering the human food supply. It would potentially affect every consumer and would be very difficult to trace.(2a) Corn products are widely used in the production of processed foods and would therefore be widely consumed on a daily basis in multiple food products.

(3) In section 5.1 of A549 under "safety assessment," the initial assessment states that the "molecular characterization of the insert has been carried out." The assumption from this point is that the transgene will stay put and be completely stable. Professor Tony Conner, a GE researcher (Crop & Food), stated at the Cartagena Biosafety Protocol meeting in Christchurch last year that it was likely that in years to come we would not be able to detect transgenes with standard techniques such as PCR because they would "no longer be intact." This lack of stability is of major concern to scientists, particularly with respect to viral promoters (CaMV 35S) switching on dormant viruses and possibly oncogenes. (3a) The molecular characterization is incomplete. The data presented does not definitively exclude the possibility that LY038 contains additional novel genes, derived either from the expression of fragments of inserted DNA or novel fusion proteins created at the junctions of inserted DNA and the maize genome.(4) A549 (section 4) states that: "conventional corn-soy-based swine and chicken are characteristically deficient in lysine and require the addition of supplemental lysine for optimal animal growth and performance." Rather than engineering corn to produce more lysine, farmers of swine and chickens should avoid the health risks of GE feed to these animals and possibly humans consuming their meat. This can be done, as is already standard practice with organic farmers, by feeding the animals food that has sufficient natural levels of lysine for optimal growth. Similarly, they should limit the amino acid arginine in their diet, to help combat viral outbreaks.

(5) There have been no independent, long-term, peer-reviewed studies proving that the ingestion of any transgenic foods are safe for humankind. Nor has the US population – being the principle country releasing untested, unlabelled genetically engineered foods over a period of years - been monitored for any resulting effects of ingesting multiple transgenic foods on a continuous, daily, long-term basis. There has been no independent scientific study to see if there is a link or not between the two- to ten-fold increase in food-borne illnesses in the US (1994 to 1999) and the commercial release of transgenic crops there from the mid 1990s onwards. In Scandinavia, where genetically engineered foods have not been widely allowed in the food chain, the same statistics have remained virtually static. Nor has the US evaluated rates for cancers or other statistically monitored health problems since the introduction of genetically engineered foods.(6) This corn is designed primarily for animal feed. The distribution of genetically engineered corn to US farms – following the rejection of genetically engineered corn by exports markets in Europe – brought reported adverse affects on stock. The markets are rejecting meat and meat products produced from animals that have consumed genetically engineered organisms.

PSRG supports a zero-tolerance level for genetically engineered organisms in foodstuffs. This is technically achievable.PSRG supports an Identity Preservation traceability system being in place on all foodstuffs to ensure that labelling accurately reflects the presence or absence of food or food ingredients produced using genetic engineering technology. Mandatory to IP traceability would facilitate quality control, the verification of labelling claims, and the possible necessity of withdrawing products should unforeseen adverse effects to human health or the environment occur. It will also facilitate the monitoring of potential effects that genetically engineered organisms could have on human and animal health and the New Zealand environment. PSRG supports mandatory fully detailed, accurate Country of Origin labelling for all packaged and unpackaged meat, fish, dairy produce, fruit and vegetables, be they in a whole form or as part of an ingredient or additive, or used in the production thereof.PSRG supports full public disclosure of all information gathered by, or required to be gathered by, government on residues in foods whether they be from pesticides, herbicides or insecticides, heavy metals, industrial chemicals or their by-products, veterinary medicines and any other contaminants, at no cost to the public. Such information is crucial in allowing New Zealanders to make informed purchasing decisions, and to meet the basic human rights of New Zealanders to know where food purchases originate.

(This submission has been prepared with the assistance of Dr Elvira Dommisse, BSc(Hons), PhD, a former GE scientist for DSIR/Crop & Food Research, Lincoln.)